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Register Committee
Ref. RC17/C12
Ver. 1.0 Date 2016-06-15 Page 1 / 3
Substantive Change Report
by the Agency for Quality Assurance through
Accreditation of Study Programmes (AQAS)
Decision of: 6 June 2016
Report received on: 3 March 2016
Agency registered since: 25.05.10
Last external review report:
February 2012
Registered until: 28/02/2017
Absented themselves from decision-making:
none
Attachments: 1. Substantive Change Report 2. Clarification Request of 19/04/16 3. AQAS Response of 24/04/16 4. AQAS Statement of 2/09/16 5. EQAR Response of 17/10/16
1. The Register Committee considered the Substantive Change Report of 1 March 2016. The Register Committee sought and received clarification from AQAS, as referred to below (see attached: request of 19/04/2016 and response of 26/04/2016).
2. The Register Committee already took note of the establishment of a separate complaints commission for AQAS’s accreditation procedures, covered in the previous Substantive Change Report of 24/01/2014.
3. The Register Committee considered the information about the establishment of AQAS ARCH, as the "daughter organisation" with the purpose of, inter alia, providing consultancy activities for higher education institutions, evaluation and certification procedures “on their own behalf” and other projects abroad.
4. Based on the information provided by AQAS and presented on the websites1 of the two organisations, the Register Committee noted that AQAS ARCH is fully owned by AQAS e.V. and managed by the same staff,
1 http://www.aqas.de/ and https://www.aqas-arch.de
Register Committee
Ref. RC17/C12
Ver. 1.0 Date 2016-06-15 Page 2 / 3
while AQAS e.V. and AQAS ARCH present themselves as linked organisations.
5. The Register Committee requested clarification on the details of the consultancy activities offered by AQAS ARCH, in particular on whether there is a clear separation between its consultancy activities and the external quality assurance activities carried out by AQAS e.V. The clarification did, however, not elaborate on any policies or practices in place to prevent any conflicts of interest between consultancy and external quality assurance.
6. In its clarification letter, the agency explained that a division of tasks was established between AQAS e.V. and AQAS ARCH, so that AQAS e.V. continues to offer accreditation of programmes and systems, whereas AQAS ARCH is the “partner” for higher education institutions, offering evaluation, consultancy projects, trainings and specific workshops. AQAS further explained that while AQAS ARCH does not award the seal of the German Accreditation Council, it carried out evaluation and certification procedures “on their own behalf”.
7. The clarification referred to work carried out by AQAS ARCH at the University of Eastern Mediterranean, Bachelor of Interior Architecture. The Register Committee understood this to refer to the accreditation of that study programme, the report of which can be found in the list of programmes accredited by AQAS e.V.2
8. Based on the information at its disposal, the Register Committee therefore concluded that the activities of AQAS e.V. and AQAS ARCH can at present not effectively be separated, given that the organisations carry closely similar names, are managed by the same staff and present themselves as related entities.
9. The Register Committee expects that agencies implement a clear and transparent separation of consultancy and quality assurance activities (see ESG 3.6 and guidelines to ESG 3.1), including appropriate policies and practices to prevent any conflicts of interest between the two. It was not clear to the Committee which policies and practices AQAS e.V. and AQAS ARCH have in place to prevent conflicts of interest between consultancy and external quality assurance.
10. Some of the activities now carried out by AQAS ARCH, namely evaluation and certification procedures, fall within the scope of the ESG. The Register Committee considered that there is no clear separation
2 See: http://www.aqas.de/wp-content/plugins/aqas/uploads/56_378_IA.pdf
Register Committee
Ref. RC17/C12
Ver. 1.0 Date 2016-06-15 Page 3 / 3
between such activities by AQAS ARCH and the activities of AQAS e.V. at present.
11. In the interest of transparency and credibility, the Register Committee expects that registered agencies either include the subsidiary’s activities (within the scope of the ESG) in the scope of their registration on EQAR, or ensure and demonstrate that the work of the subsidiary can effectively be distinguished from the registered agency. In the former case, it is expected that the subsidiary’s activities comply with the ESG. In the latter case, it is expected that the agency ensures and is able to demonstrate that there is no risk of confusion whatsoever towards the outside world, for instance in that an evaluation or certification carried out by the subsidiary might be brought in connection with the parent organisation, its registration on EQAR or the ESG.
12. Based on the information at its disposal, the Register Committee was unable to determine whether AQAS made a clear choice for either option and implemented it accordingly. The Register Committee was therefore concerned whether the criteria for inclusion on the Register remain fulfilled.
13. The Register Committee concluded that it would not be practical to consider reducing the remaining validity of registration, according to §8.4c of the EQAR Procedures for Applications, and thereby request an earlier external review of the agency, since the regular periodic review of AQAS is already underway and due to be completed before expiry of AQAS' registration in February 2017.
14. The Register Committee underlined that the external review should address the issues addressed in paragraphs 8 to 11 above.
Von: [email protected] [email protected]: Substantive Change Report: AQAS e.V.Datum: 03. März 2016 14:16
Reference # 9271484
Status Complete
Agency #1 * AQAS e.V.
Expiry date #1*
28/02/2017
Contact #1 * Doris Herrmann
Phone #1 * +49 221 99 50 06 21
Email #1 * [email protected]
Otherorganisations?*
No
A. Has theorganisationalidentity of theregisteredagencychanged? *
Yes
Description * AQAS e.V. established in 2002 - is an agency for quality assurance in the higher educationarea. The agency provides processes for the accreditation of programmes and qualityassurance systems. AQAS is accredited by the German Accreditation Council andauthorized to award its seal to German degree programmes and institutionsAQAS ARCH was founded as a "daughter organisation" of AQAS e.V. on january 1st in2015, to provide consultancy activities for HEIs which exceed the level of accreditationprocedures that come within the ambit of AQAS e.V.
B. Has theorganisationalstructurechanged? *
Yes
Description * In may 2013 AQAS e.V. established a complaints commission to asses complaintssubmitted by universities referring to the decisions of one of the Commissions forAccreditation in an accreditation procedure, which could not be solved by a repeatedconsultation of the Commissions for Accreditation. In accordance to the statutes, it aims tofind a final decision for the association.
C.i. Are therenew types ofactivities? *
No
C.ii. Are therechanges inexistingactivities? *
No
C.iii. Havesome or allexistingactivities beendiscontinued?*
No
Last Update 2016-03-03 07:16:39
EQAR | Oudergemselaan/Av. d’Auderghem 36 | BE-1040 Brussels
EQAR Founding Members:
European Quality Assurance Register for Higher Education (EQAR) aisbl
Avenue d’Auderghem/ Oudergemselaan 36 1040 Brussels – Belgium
Phone: +32 2 234 39 12 Fax: +32 2 230 33 47
[email protected] www.eqar.eu
VAT BE 0897.690.557
Agency for Quality Assurance through Accreditation of Study Programmes (AQAS) Ms Doris Herrmann
– by email –
Brussels, 19 April 2016
Substantive Change Report – Clarification Request
Dear Doris,
We wish to thank you for the Substantive Change Report of 3 March 2016. Your report has been reviewed by two rapporteurs before being brought to the attention of the entire EQAR Register Committee.
In order to prepare consideration by the Committee, we would be obliged if you could clarify the following query.
We note from the Substantive Change Report that AQAS established a "daughter organisation" - AQAS ARCH on 1 January 2015 to provide consultancy activities for higher education institutions.
As this is not addressed in the submitted documentation can you please clarify and provide further details on how are the consultation activities offered by AQAS ARCH separated from the external quality assurance activities carried out by AQAS e.V.?
In order to expedite proceedings we kindly ask you for a reply by 29 April 2016. Please inform us if any difficulties arise in meeting this deadline.
I shall be at your disposal if you have any further questions or inquiries.
Kind regards,
Colin Tück (Director)
EQAR | Oudergemselaan/Av. d’Auderghem 36 | BE-1040 Brussels
AQASEberhard MenzelHohenstaufenring 30-32
50674 KölnGermany
Brussels, 17 October 2016
Substantive Change Report by AQAS e.V.Your letter of 2/9/2016
Dear Mr Menzel,
I would like to clarify some points in response to your comments on the Register Committee's decision of 6/6/2016.
1. Consultancy projects and the organisation of workshops are not activities within the scope of the ESG. These do, therefore, not need to be reviewed against ESG 2.1 – 2.7 in the ongoing external review of AQAS.
The Register Committee's concern was whether there is a clear separation between consultancy activities and external quality assurance activities, with adequate policies in place to prevent any conflicts of interest between them.
With regard thereto, your letter of 2/9/2016 clarified that AQAS has a policy of not offering accreditation to institutions that were consulted by AQAS ARCH. I thank you for this clarification, which was not obvious from previous communications.
2. The Register Committee's second concern was whether AQAS ARCH carries out any activities within the scope of the Standards and Guidelinesfor Quality Assurance in the European Higher Education Area (ESG), such as review, audit, evaluation or accreditation of higher education institutions or programmes, concerning learning and teaching in higher education, including the learning environment and relevant links to research and innovation.
3. The Register Committee considered the same for the other agencies mentioned in your letter. It was either clear that the respective subsidiaries do not carry out activities within the scope of the ESG, or it was requested that the relevant activities be reviewed and assessed against the ESG.
EQAR Founding Members:
European Quality Assurance Register for Higher Education (EQAR) aisbl
Avenue d’Auderghem/ Oudergemselaan 361040 Brussels – Belgium
Phone: +32 2 234 39 12Fax: +32 2 230 33 47
VAT BE 0897.690.557
In all cases where either agencies or their subsidiaries carry out consultancy activities, the Register Committee did address the separationbetween external quality assurance and consultancy.
4. I thank you for clarifying that the programme accreditation carried out by AQAS ARCH was an exceptional case and that AQAS ARCH will no longer carry out accreditation procedures.
Your letter, however, mentions that AQAS ARCH carries out “certification of trainings and further education”. Likewise, AQAS' earlier clarification noted that AQAS ARCH carries out evaluation and certification procedures“on their own behalf”.
The Register Committee therefore expects (see our letter of 30 June 2016) that AQAS, within the ongoing external review by GAC, clarifies whether or not those activities are within the scope of the ESG, and that this is confirmed by the external review panel.
Should AQAS ARCH carry out any activities within the scope of the ESG, the Register Committee expects that those are either (a) implemented in compliance with the ESG and that this is demonstrated in the external review, or (b) that AQAS demonstrates that there is a clear separation between ESG-compliant activities of AQAS and non-compliant activities ofAQAS ARCH, and that there is no risk of confusion whatsoever.
Should AQAS ARCH's activities be entirely outside the scope of the ESG, this should be confirmed by the external review panel.
5. After considering your report and additional clarification, the Register Committee took note of AQAS' Substantive Change Report and requested that the issues mentioned be addressed in the anyway ongoing external review of AQAS.
The Register Committee did not make any other conclusions and will get back to the matter once it has received the review panel's report.
In order to make this further exchange transparent, we will publish your letter as requested, along with our decision of 6 June 2016 and the present response. I remain at your disposal for any further questions.
Yours sincerely,
Colin Tück(Director)
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